Petitioner Niles filed a joint income tax return with his wife for the year 1961 reporting total receipts of $42,035.71 from two clients, J. G. White and Co. and Berry Motors, Inc. In 1964 the State Department of Taxation and Finance issued a notice of deficiency of personal income tax due for the year 1961, covering an assessment of $1,284 plus penalty and interest for unincorporated business tax due pursuant to article 23 of the Tax Law...
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